This blog replaces the earlier archives I had posted on the Internet and includes various memos sent to the clients of the VitaminLawyer.com (now the Vitamin Consultancy). It includes archived copies of memos from 2004 through 2007 and subsequent memos will be posted as they are issued.

[I was asked to repeat this information from previous eMemos. I’ve created a new web page with outlines of the contents of the SoP and EM documents -http://tinyurl.com/2eu6yj Updated: www.VitaminIndustryCompliance.com]

A primary concern of small, leading edge dietary supplement purveyors is how to deal with the new wave of regulation that seems to be sweeping the industry. The first rule of bureaucracy is, “Are your papers in order?” Well, are they? In the context of current Good Manufacturing/Marketing Practices (cGMPs) your “papers” are the documentation of your business activities, from buying your products, through advertising, selling and shipping them. And then, dealing with customer issues, refunds, recalls, adverse event claims, etc., etc.

To make it as simple as possible, I’ve developed a shorter and simpler “Record Keeping SoP” version of my Standard Operating Procedures/Employee Handbook (SoP/EMs) that is made for smaller, Internet oriented dietary supplement and alternative therapy companies. For a bit over an hour of my time, I can customize the Record Keeping SoP format for your company, so you will know what documents you need to keep and for how long. Just email me at ralph.fucetola@usa.net with “Record SoP” in the subject line and I’ll let you know what information I need and how you can reserve the time for your SoP.

You can now also take a look at the Tables of Contents of the Record Keeping SoP (actual document: 5 pages), the Standard SoP Manual (16 pages) and the Employee Manual (22 single-spaced pages) that I’ve posted at: http://tinyurl.com/2eu6yj

“2/28/2007 - A meta-analysis of 68 randomized trials with antioxidant supplements has reported that vitamins A and E, and beta-carotene may increase mortality risk by up to 16 per cent, but vitamin C did not have an effect on mortality and the antioxidant mineral selenium was associated with a nine per cent decrease in all-cause mortality. … The pooled analysis, published in the Journal of the American Medical Association, could have significant negative effects on the sale of antioxidant dietary supplements… The new pooled analysis has already drawn criticism from both inside and outside the dietary supplements industry concerning the methodology applied, and the conclusions drawn. … The most prevalent criticism of the study has come from the diverse nature of the studies pooled together, described by one industry expert as comparing "apples and oranges"… A wealth of epidemiological evidence has linked dietary antioxidant intake to reduced risk of a wide-range of diseases, such as cancer and cardiovascular disease, but when such
antioxidants have been extracted and purified, or synthesized and put into supplements, the antioxidants, according to randomized clinical trials (RCTs), do not always produce the same positive results. … [The meta-analysis] findings contradict the findings of observational studies… that antioxidants improve health.”

The language used in the reports about the meta-analysis does appear carefully chosen to overstate the risks and understate the benefits. The bottom line for vitamin purveyors: (1) if these allegations begin to impact the market, consider substituting whole food sources of ingredients for extracts; (2) budget the funding needed for RCTs and (3) note the astoundingly positive results for Selenium: a 9% decrease in mortality. Think Whole Food Supplements!

[03/02 Update: Linus Pauling Institute blasts AMA fake meta-analysis: http://www.sciencedaily.com/releases/2007/02/070228172604.htm -- the Institute points out obvious flaws in the report and show the bias of the authors, who started with 815 trials, selected out 68 of them, ignored the most valid trials, and then manipulated the statistics to provide the preordained result. Voodoo science at its most obvious.]

"Just when you believed you had all your SEO tactics figured out, the web goes and changes on you. ... Web 2.0 changes the whole ballgame. It not only places the Internet user squarely in the middle of things, but it gives that user the means and power to create and manipulate data. Web 2.0 dramatically changes how we view and use the web. ... Just what exactly is Web 2.0? ...perhaps the simple definition can be found in the word "you"! Time magazine probably summed it up best by making reference to the "you" in user generated content. Web 2.0 is basically all the platforms that give us this brave new user-powered interactive Internet, generally referred to as 'social media'. .. Web 2.0 can be seen or manifested in such sites as YouTube, MySpace, Del.icio.us, Digg, Squidoo. ... Web 2.0 uses scripting languages such as Python, Perl PHP, RSS... to construct interactive platforms that websites can use to create all this user-generated content. ... If you have used Google Earth, you will realize how powerful and revolutionary these new applications
can be, not to mention, they are a whole lot of fun. ... all webmasters should optimize their sites for this new Web 2.0 and take full advantage of all the SEO possibilities presented by this brave new Internet. … Here are a few SEO suggestions you can try:

1. RSS/Blogging. You must place a blog and RSS feed on all your sites. This is a fairly simple procedure to do with free server-based programs... Having a blog and RSS feed will place your site into the whole tagging process. Each category you create in your blog will be seen as a tag by such sites as Technorati. RSS stands for 'Really Simple Syndication' and your RSS feeds will get your content distributed across the web. ...

2. Create some Google Juice! Join as many of these highly interactive sites as you can: MySpace, YouTube, Del.icio.us, Digg, Wikipedia ... my favorite is Squidoo, where you can create Lenses on different topics that interest you. User driven content that's utilized by all the major social media sites. Of course, link back to your sites in your posts and creations in these user-created content havens and watch your PR ratings go way up.

3. Use Interactive Scripts. Place interactive JavaScripts and platforms on your own sites. Have membership forums, polls, blogs, feedback forms, user-contributions... to build unique content driven sites. Become the spider!

4. Tagging (Folksonomy). Be constantly aware of the tags (keywords) you're creating with your blogs and sites. This can have a very beneficial effect on your traffic and rankings. Closely relate these tags to the content on your sites and build higher rankings in all the major search engines.

5. The Long Tail. Especially important for affiliate marketers, you need to cover special niches where there is less competition and content. These narrow niches make up a large portion of the whole vast web, creating content in these unique areas will get your site included in the search engines a lot quicker and keep them there a lot longer.

6. Holistic Web 2.0! Be constantly vigilant in placing your sites in the whole 'Interactive Game', building links and partnerships with the important YouHubs: MySpace, Del.icio.us, YouTube, Digg, Squidoo... the more connections you have, the more your own sites will prosper.

"... Web 2.0 will play an ever increasing role in the development and evolution of the web. Make sure your sites are optimized and in the 'You' game. Create blogs, RSS feeds, interactive forums, membership areas, user-generated content and truly make your sites interactive havens in their own right. Just remember to tag everything and your sites will reap the benefits of this new Web 2.0 generated SEO gold rush. ... The author [Titus Hoskins] is a full time Internet Marketer with numerous sites on the web, including two niche sites on Internet Marketing. His main site is www.bizwaremagic.com ...”

About Me

The Vitamin Conslutancy - www.vitaminconsultancy.com -- I practiced law for 36 years in NJ (1971 - 2006), gaining a reputation as The Vitamin Lawyer, representing people in the Natural Products, Dietary Supplements and CAM (Complementary and Alternative Modalities) fields. Now I provide educational services and I consult with lawyers and other professionals, formulators, manufacturers and purveyors of natural and nutritional products, as well as with CAM enterprises and practitioners.
I started these blogs to comment on health and freedom issues and to provide an archive of information for my clients and associates. This is a private expressive association communication.
I have been a trustee of several NGOs (nongovernmental organizations) including the Natural Solutions Foundation - globalhealthfreedom.org - Institute for Health Research - inhere.org - Sound Health Research Institute - soundhealthresearch.org and LifeSpirit Church - lifespirit.org